Kountable, Inc. (“Kountable”) enables users to receive an analysis of their social capital, which in turn enables those users to obtain other services to facilitate their entrepreneurial projects that they describe to us. Kountable is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect: through our website, www.kountable.com (the “Website”); through software applications made available by us for use on or through computers and mobile devices (the “App”); through our HTML-formatted email messages that link to this Privacy Policy; and through our social-capital analytics process, which enables us to provide users with a “kScore” they may use to seek funding or other services in connection with entrepreneurial projects, together with our online platform through which users can seek this type of service or funding (collectively, the “Services”).
By providing Personal Information to us, you agree to this Privacy Policy.
Personal Information
Personal Information we may collect
“Personal Information” is information that identifies you as an individual or relates to an identifiable person. We collect different levels of personal information about you depending on the activities you undertake in connection with the Services.
You can use the publicly available portions of our Website without submitting any Personal Information. You may elect to submit Personal Information (such as your email address) through our Website to learn more about our Services.
If you choose to download our App or create an account with us, we may collect additional Personal Information from you as described below.
- Creating, Updating or Enhancing Your kScore:
After you download the App, we may collect information from your device to create an initial kScore for you. For us to create a kScore, you must grant us permission to access data from your mobile device (which may include your contact lists, content and transmission details of emails and text messages you have sent and received, and call history, depending on the permissions you choose to grant). In addition, if you connect to a social media account through the Services, we may collect information from your social media profile and information about your social media connections (such as basic demographic information from Facebook). If you connect to a webmail account through the Services, we may use our automated systems to analyze your communications content and the metadata associated with those communications to refine further your kScore. We also may collect publicly available information about you such as Internet search results. - Account Creation:
When you create an account through our Website or App, we ask you to provide an email address and/or to log in with a social media account. If you elect to use your social media account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles (only as permitted via that social media’s standardized data collection tools provided to companies like Kountable), so that we can create a kScore, as described above. We may also collect additional information prior to your submitting a project, such as your personal and business addresses, your email address, and information about you or your business. - Submitting a Project:
If you submit information about a project through the Services, we may request comprehensive information (about you, your project, and your business) in order to verify your identity and your business’ identity and evaluate your project. This may include, but is not necessarily limited to, financial information including bank account numbers and balances, loan numbers and amounts, national identity number and documents (such as a Passport or Social Security number), biometric information such as facial geometry or fingerprints, precise geolocation information (including location history), employment information, business information including registration documents, contracts, ownership records, and similar information.
PLEASE NOTE: If you submit or allow us to collect any Personal Information relating to other people in connection with your use of the Website or Apps or the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
How We May Collect Personal Information
We and our service providers may collect Personal Information in a variety of ways, including:
- Through your use of the Website or App:
We may collect Personal Information when, for example, you register to receive marketing communications from us, or when you create an account or use the Services to create, update or enhance your kScore or submit a project. - From Other Sources:
We may receive your Personal Information from other sources, such as public databases and search engines, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. For example, if you elect to connect your social media account to your account with us, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.
How We May Use Personal Information
We may use Personal Information:
- To offer the Services, including determining your kScore and evaluating your projects (such as completing background checks required for us to participate in a project).
- To respond to your inquiries and fulfill your requests, such as to send you newsletters.
- To send administrative information to you, for example, information regarding the Services or our Website and Apps, and changes to our terms, conditions and policies.
- To communicate with you about a project submission or in connection with a possible project or your use of our Services.
- To send you marketing communications that we believe may be of interest to you, if you have opted-in to receive such communications.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully.
- To generate de-identified or aggregated user data to share with researchers whose areas of study may include aspects of social networks among entrepreneurs and other associated topics.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Website or Apps, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
How Personal Information May Be Disclosed
Your Personal Information may be disclosed:
- To our affiliates for the purposes described in this Privacy Policy.
- To our third party service providers who provide services such as website hosting, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To potential providers of capital for a project that you submit information about.
- To third parties, to permit them to send you marketing communications, consistent with your choices if you have opted into such sharing.
- To third-party sponsors of sweepstakes, contests and similar promotions.
- To identify you to anyone to whom you send messages through the Services.
- By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business (including particular projects that we facilitate), assets or stock (including in connection with any bankruptcy or similar proceedings).
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or OTHERS; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Other Information
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you
- Aggregated or de-identified information
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.
How We May Collect Other Information
We and our third party service providers may collect Other Information in a variety of ways when you use the Website or Apps, including:
- Through your browser or device:
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the App you are using. We use this information to ensure that our Website, Apps, and the Services function properly. - Through your use of the App:
When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. - Using cookies:
Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Website or Apps, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while and to recognize your computer in order to assist your use of the Website or App, including for purposes of the Services. We also gather statistical information about use of the Website and Apps in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.
If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Website or App. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.
- Using pixel tags and other similar technologies:
Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Website or Apps to, among other things, track the actions of users of Kountable (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Website and Apps and response rates. - Analytics:
We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Website or Apps and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout. - IP Address:
Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Website or Apps, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Website and Apps. We may also derive your approximate location from your IP address. - Physical Location:
We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content, and for purposes of providing the Services. - From you:
Information such as your preferred means of communication is collected when you voluntarily provide it. - By aggregating or de-identifying information:
Aggregated or de-identified Personal Information does not personally identify you or any other user of the Website, App, or Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information (such as combining your name with your location). If we do, we will treat the combined information as Personal Information as long as it is combined.
Third Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which our Website or Apps link. The inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps.
Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Access
Your choices regarding our use and disclosure of your Personal Information
If you no longer want to receive marketing-related emails from us, you may opt-out by following the unsubscribe instructions at the bottom of each such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access and update your Personal Information
If you would like to review, correct, update, or request suppression or deletion of Personal Information that you have previously provided to us, you may contact us by email at privacy@kountable.com.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make enter into a transaction, you may not be able to change or delete the Personal Information provided until after the completion of such transaction and any related retention period). There may also be residual information that will remain within our databases and other records, which will not be removed.
Please also note that if your request relates to information provided in connection with the Services, we may need to nevertheless maintain certain information to comply with applicable laws and to provide you with services relating to the kScore.
Retention Period
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Use of Services by Minors
The Website, Apps, and the Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Information to us or otherwise use the Services.
Cross-Border Transfers
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Website or App you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
Sensitive Information
Unless specifically requested in connection with the Services, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Website or Apps or otherwise to us.
Updates to this Privacy Policy
We may change this Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy. Your use of any Kountable services, including the Website or App, following these changes means that you accept the revised Privacy Policy.
Contacting Us
If you have any questions about this Privacy Policy, please contact us at privacy@kountable.com or:
Kountable, Inc.
321 Pacific Ave
San Francisco, CA 94111
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
